Privacy Policy

PRIVACY POLICY / TERMS AND CONDITIONS NOTICE

BY ACCESSING AND USING THIS WEBSITE / MOBILE APPLICATION, THE USER CONSENTS TO THE PROCESSING OF THEIR PERSONAL INFORMATION BY RUNAKO CONNECT ON THE BASIS SET OUT IN THIS PRIVACY NOTICE. IF THE USER DOES NOT CONSENT, THE USER MUST IMMEDIATELY STOP ACCESSING AND/OR USING THIS WEBSITE / MOBILE APPLICATION.

INTRODUCTION

  1. Runako Connect collects, uses and, in some circumstances, shares the personal information of Users in and through this website / mobile application.

  2. Runako Connect respects the rights of Users whose personal information is collected and used by it, including their right to protection against the unlawful collection, retention, sharing and use of such personal information.

  3. The purpose of this Privacy Notice is to provide Users with information about the information processing activities of Runako Connect and the manner in which their rights are protected.

  4. This Privacy Notice shall serve as a blanket notification to Users about Runako Connect’s processing activities which will remain valid for a 12 month period. Users will not be notified separately on each occasion that Runako Connect processes the same personal information in the same way over the 12 month period.

  5. Runako Connect may amend the provisions of this Privacy Notice to comply with any changes in the law, and/or pursuant to any changes to its information processing activities or privacy practices. Such amendments will be published on the website / mobile application and will become operable from the date of such publication.

  6. The provisions of this Privacy Notice must, as far as possible, be incorporated into the agreement between Runako Connect and Users of this website / mobile application.

 

DEFINITIONS AND INTERPRETATION

  1. In this Privacy Notice, the following words bear the following meanings:

    1. ‘’consent’’ means any voluntary, specific and informed expression of will in terms of which permission is given by or on behalf of a User for the processing of their personal information;

    2. ‘‘direct marketing’’ means to approach a data subject, either in person or by mail or electronic communication, for the direct or indirect purpose of promoting or offering to supply any goods or services to the data subject;

    3. ‘’information officer’’ means The current nominated Lead application administrator at Runako Connect

    4. ‘‘operator’’ means an outside third party who processes personal information for or on behalf of Runako Connect in terms of a contract or mandate;

    5. ‘’personal information’’ means any information linked to a User or information that can identify a User, including but not limited to:

      1. ‘’the website / mobile application’’ means the website / mobile application or any part thereof which is accessible from www.runakoconnect.co.zw or www.runakoconnect.com

      2. ‘’User’’ means a visitor or user of this website / mobile application, or any of the content or services associated with this website / mobile application;

      3. ‘’special personal information’’ means information relating to a User’s religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health, sex life, biometric information or criminal record;

      4. ‘’process or processing’’ means, in relation to personal information, any operation or activity or any set of operations, whether or not by automatic means, including:

        1. the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use of that information;

        2. dissemination by means of transmission, distribution or making available in any other form; or

        3. merging, linking, as well as restriction, degradation, erasure or destruction of that information;

      5. information relating to a User’s race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth;

      6. information relating to a User’s education or their medical, financial, criminal or employment history;

      7. a User’s identity number, e-mail address, physical address, telephone number, location information or online identifier;

      8. a User’s biometric information, including fingerprints, DNA or retina scans;

      9. a User’s personal opinions, views or preferences;

      10. correspondence sent by a User which is of a private or confidential nature;

      11. the views or opinions of others about a User; and the User’s name if it appears with other personal information relating to that User, or if the disclosure of their name on its own would reveal further personal information about that User;

  1. Any reference in this Privacy Policy to:

    1. the singular includes the plural and vice versa;

    2. any one gender includes the other genders, as the case may be;

    3. an act, regulation or other law is to the version of that law in force at the effective date of this notice and includes any amendment or re-enactment made to that law after the effective date of this notice.

  2. When calculating any number of days for the purposes of this notice, the first day must be excluded and the last day of the relevant interval included, unless the last day is not a business day, then the last day will be the next succeeding business day.

  3. The word “include” means “include without limitation”. Use of the word ‘’include’’ or ‘’in particular’’ is for illustration or emphasis only and where followed by specific examples must not be interpreted as limiting the meaning of the general wording preceding it.

RESPONSIBLE PARTY

  1. Runako Connect will be the party who will be collecting and processing a User’s personal information and as such is designated as the ‘’responsible party’’ for the purposes of this Notice.

  2. Runako Connect’s contact details are as follows:

 

Postal address: 275 Herbert Chitepo avenue Harare

Telephone number: +263 078 733 0215

Email address: info@runakoconnect.co.zw

Website / mobile application address: www.runakoconnect.co.zw

  1. Runako Connect may instruct third party operators from time to time to undertake certain processing activities relating to the User’s personal information.

 

WHAT PERSONAL INFORMATION IS COLLECTED

  1. Runako Connect may collect the following personal information from the User:

    1. Initials, first name, surname;

    2. Identity number and/or date of birth;

    3. Physical and postal address;

    4. Email address;

    5. Telephone and cellphone numbers;

    6. User’s personal opinions, views or preferences;

    7. correspondence sent by a User which is of a private or confidential nature;

    8. the views or opinions of others about a User; and

  2. The supply of personal information by the User to Runako Connect is voluntary and not mandatory. However, if the User refuses to supply any personal information, certain consequences may naturally flow from such a refusal, such as preventing the user from accessing the application or some of its features.

  3. There is no applicable law which directly requires or authorises Runako Connect to collect a User’s personal information.

 

 

PURPOSE/S FOR COLLECTION AND PROCESSING OF PERSONAL INFORMATION

  1. Runako Connect shall only collect a User’s personal information for a specific, explicitly defined and lawful purpose relating to a function of the application or activity of Runako Connect’s business.

  2. Such purposes may include the following:

    1. To enable Runako connect to identify any individual discrete user of the app thereby allowing appropriate provision of the service to that specific user.

    2. to perform any obligations under a contract with a User;

    3. to protect a legitimate interest of a User (unless the User has specifically objected in writing to all or some of the processing activities on reasonable grounds);

    4. to pursue its own legitimate interests or the legitimate interests of a third party who it is sharing the information with (unless the User has specifically objected in writing to all or some of the processing activities on reasonable grounds);

    5. to process personal information for direct marketing purposes (unless the User has opted out of receiving any direct marketing material);

    6. to present content to the User in the most effective way for them and their viewing device and browser;

    7. To customise and display content including, but not limited to products, articles, listings and advertisement to the User in a way that Runako Connect feels may interest the User or be most beneficial to them;

    8. To send content including, but not limited to products, articles, listings and advertisement content to the User via email or other electronic media, where the User has consented to be contacted by Runako Connect with such content;

    9. To enable the User to voluntarily participate in interactive features on the website / mobile application;

    10. To notify the User about changes to the website / mobile application;

    11. To contact the User regarding their orders and/or deliveries.

  3. If Runako Connect intends to process a User’s personal information for any other purpose not listed in clause 5.2 or which is otherwise not automatically permitted by law, it shall ensure that it obtains the User’s written consent to do so.

 

COLLECTION DIRECTLY FROM USER

  1. Runako Connect shall, as far as possible, always collect personal information about a User directly from the User, except in the following circumstances:

  2. Where personal information is collected from a public record, or from another source if the information has already been made public by the User;

    1. where the User has given their written consent to Runako Connect to collect their information from another source;

    2. where the collection of a User’s personal information from another source will not prejudice any of the User’s legitimate interests;

    3. where the collection of personal information from another source is necessary to maintain Runako Connect’s legitimate interests or those of any third party it intends sharing the information with;

    4. where the collection of personal information directly from the User would prejudice the purpose for the collection;

    5. where the collection of personal information directly from the User is not reasonably practicable in the circumstances.

  3. If Runako Connect collects personal information from a source other than the User, it shall record in writing the details of that source, including the full names and contact details of that source where applicable.

  4. Personal information may be collected from or supplied by the User in any of the following ways:

    1. during the process of registering as a member on this website / mobile application;

    2. provided by the User as part of their profile pages on the website / mobile application;

    3. when subscribing to a service, entering into a competition or promotion, or participating in a survey offered on this website / mobile application;

    4. when posting a comment, review, reply or recommendation on this website / mobile application;

    5. when requesting further services or information from Runako Connect;

    6. when contacting Runako Connect to report a problem with the website / mobile application or for any other reason;

    7. when completing any forms on the website / mobile application.

  5. The User may visit the website / mobile application without providing any personal information. However, the website / mobile application’s servers may still collect technical information regarding the use of the website / mobile application, which is aggregated for analytical purposes, technical maintenance and for improving the content offered on the website / mobile application. Such information may include details of the User’s visit, information about the User’s computer, including IP (Internet Protocol) address, operating system and browser type, the User’s location, and usage information. An individual User will not be identified from or by this information and Runako Connect is entitled to copy, distribute or otherwise use such information without limitation.

 

 

COOKIES

  1. “Cookies” are small text files transferred by a webserver to a User’s hard drive and thereafter stored on their computer.  The types of information a Cookie collects includes a User’s username, the date and time of their visits to the website / mobile application, their browsing history and preferences.

  2. Runako Connect uses Cookies on this website / mobile application to:

  3. distinguish one User from another on the website / mobile application;

  4. remember the User’s last session when they return to the website / mobile application;

  5. estimate the website / mobile application’s audience size and usage patterns;

  6. store information about the User’s preferences, which allows Runako Connect to customize the website / mobile application and content according to the Users individual preferences; and

  7. speed up searches on the website / mobile application.

  8. The provisions of this clause are only applicable to Cookies used by Runako Connect. In some instances, third-party service providers may use Cookies on the website / mobile application. Runako Connect cannot and does not control or access Cookies used by third party service providers and takes no responsibility therefor.

  9. The User has the right and ability to either accept or decline the use of Cookies on their computer’s web browser, whether they are logged in as a member, or simply casually visiting the website / mobile application. However, declining the use of Cookies may limit a User’s access to certain features on the website / mobile application.

GENERAL CONDITIONS FOR PROCESSING PERSONAL INFORMATION

  1. Runako Connect shall comply with all laws of Zimbabwe (the country of registration of the company), contracts or regulations when it processes a User’s personal information.

  2. Runako Connect shall not act unreasonably when processing a User’s personal information. This means that it will collect and process a User’s personal information in a way that the User can reasonably expect and in a way that is fair.

  3. Runako Connect shall respect the User’s right to privacy at all times. If there is another way in which it can achieve the same goal without posing any risk of harm to the privacy rights of the User, then it will choose that option.

  4. Similarly, if Runako Connect needs to process personal information but there are less privacy-invasive methods of collecting, using and sharing that information, then it will use those methods.

  5. Runako Connect shall ensure that the personal information that is collected and processed is and remains relevant to the identified purpose/s for such processing, and that such information is and remains adequate, but not excessive, for achieving the identified purpose/s.

  6. If there are any alternative ways to achieve the identified purpose/s without processing personal information, Runako Connect shall not process that personal information.

  7. Runako Connect shall ensure that the processing activities it chooses to apply are proportionate to achieving the identified purpose/s and that no less privacy invasive measures are available to achieve the same purpose/s.

  8. Runako Connect shall ensure that, regardless of the stated purpose/s for processing personal information, the rights and interests of Users will not be unnecessarily prejudiced or infringed, unless it cannot be avoided, and then in such cases, it shall ensure that its own rights and/or interests justify such prejudice or infringement taking place.

  9. Once Runako Connect has achieved the purpose for the collection of the User’s personal information, it will destroy or delete such information, unless the User has directed otherwise in writing, or Runako Connect is required by law to retain the information for a longer period of time.

  10. If Runako Connect no longer needs to process personal information to achieve the purpose originally specified, it will stop using that information.

DISCLOSURE AND SHARING OF PERSONAL INFORMATION

 

  1. Runako Connect may, in the course of providing any content or services on this website / mobile application, or for the purposes of concluding or performing any sale or other transaction with a User, share certain personal information with third party operators who perform certain processing activities on behalf of Runako Connect.

  2. The information shared and the categories of third party operators with whom it is shared is set out below:

  3. Payment Gateway Provider (User’s full names, credit card details, banking details);

  4. Bulk email delivery providers (User’s email addresses).

  5. Runako Connect may also share aggregated information about Users of this website / mobile application and their usage patterns.

  6. Other than as stated in clause 9.1 and 9.3, Runako Connect shall not share a User’s personal information with any third parties unless it has the User’s express consent to do so, or activation of the said service.

  1. USER’S RIGHTS IN RELATION TO THE PROCESSING OF THEIR PERSONAL INFORMATION

    1. Users shall have the following rights in relation to the processing of their personal information:

      1. to access and correct any personal  information held by Runako Connect about them;

      2. to object to the processing of their information; and

      3. to lodge a complaint with the Information Regulator.

FURTHER PROCESSING

  1. Runako Connect shall not process a User’s personal information for any purpose not previously specified except in the following circumstances:

  2. where the User has consented to such further processing;

  3. where the further processing is necessary for the exercise of any contractual rights or the fulfillment of any obligations between Runako Connect and the User;

  4. where the further processing activities are linked to or compatible with the original purpose;

  5. where the further processing is necessary for the prevention, detection, investigation, prosecution and punishment of an offence;

  6. where the further processing is necessary to enforce any law;

  7. where the further processing is necessary for the conduct of legal proceedings in any court or tribunal that have commenced or are reasonably contemplated;

  8. where the further processing is necessary to prevent or mitigate a serious and imminent threat to the life or health of the User or another individual;

  9. where the further processing is necessary for historical, statistical or research purposes.

  10. Runako Connect shall ensure that if it intends processing personal information for other purposes not previously specified, it shall notify the User of such further purposes and the possible consequences of the intended further processing for the User.

 

ACCURACY, CORRECTNESS AND COMPLETENESS OF PERSONAL INFORMATION

  1. Runako Connect shall take reasonably practicable steps to ensure that the personal information kept by it about Users is complete, accurate, not misleading and is updated when necessary.

  2. However, if a User is aware of any personal information in Runako Connect’s custody that is incorrect, inaccurate or which needs to be updated, the User must make a written request to Runako Connect’s information officer at admin@runakoconnect.co.zw to update or correct the relevant information.

  3. If a User has contested the accuracy of any personal information being used by Runako Connect, it shall immediately stop using that information until its accuracy has been verified.

  4. Runako Connect reserves its right to only adhere to a request from a User in terms of clause 12.2 if the correction or updating of that information will result in the personal information being correct and accurate.

  5. Where personal information that has been shared by Runako Connect with a third party is subsequently updated or corrected, Runako Connect shall ensure that all third parties, with whom that information was shared, receives the updated and/or corrected version of the information as soon as it has been updated and/or corrected.

 

 

SECURITY SAFEGUARDS

  1. Runako Connect is committed to protecting the personal information in its custody against any loss of, damage to or unauthorised destruction of that information, and to prevent any unauthorised parties from accessing that information.

  2. Runako Connect takes steps to continually identify and document any risks to the personal information it has in its possession or under its control and that appropriate security safeguards are in place against those risks.

  3. Runako Connect shall ensure that in any contracts entered into with third party operators who process personal information on Runako Connect’s behalf, include the following obligations:

  4. the operator shall not process any personal information without Runako Connect’s  knowledge and authority;

  5. the operator shall treat all personal information given to it as confidential and shall not disclose it to any unauthorised third parties;

  6. the operator shall establish and maintain adequate security measures which are the same or offer similar protection over the personal information as that employed by Runako Connect;

  7. the operator shall notify Runako Connect immediately where there are reasonable grounds to believe that any personal information has been leaked to or accessed by any unauthorised person;

  8. if the operator is situated in another country, it must comply with the data protection laws in that country and be able to provide verification that it is so compliant;

  9. if an operator is legally obliged to disclose any personal information processed by them on Runako Connect’s behalf to other parties, it must notify Runako Connect beforehand to enable Runako Connect and/or individual Users to protect their rights if necessary.

  10. Users must maintain the secrecy of any passwords used to gain access to this website / mobile application and should change such passwords regularly.

  11. Runako Connect shall ensure that all personal information on its systems is properly backed-up and that back-up copies are stored separately from the live files.

 

NOTIFICATION OF BREACH OF SECURITY

  1. If personal information about a User is inadvertently leaked or Runako Connect’s security has been unlawfully breached by any unauthorised party, Runako Connect shall immediately identify the relevant Users who may be affected by the security breach, and shall contact them at their last known email address or contact details or by the quickest means possible.

  2. Runako Connect shall provide sufficient information to the User to allow him or her to take the necessary protective measures against the potential consequences of the compromise, or shall advise Users of the steps to be taken by them and the possible consequences that may ensue from the breach for them.

 

 

DECISIONS BASED ON PERSONAL INFORMATION PROCESSED

  1. If Runako Connect is required to make a decision about a User using any personal information that has been obtained, it shall ensure that a record of such information and the decision made is kept for a reasonable period of time to give the User an opportunity to request access to that record.

  2. Runako Connect shall allow a User a reasonable opportunity to make representations before any decision is made solely on the basis of the personal information processed, if that decision will affect the legal position of the User, or will otherwise adversely affect them in some manner or form.

  3. Runako Connect shall always ensure that the underlying logic behind any decision made pursuant to the automated processing of personal information is sound and that this underlying logic can be communicated to the User to enable them to make representations.

  4. If Runako Connect has made a decision based on incorrect personal information, it shall immediately revisit that decision as soon as it receive notice or becomes aware of the error or inaccuracy of that information.

 

LINKED THIRD PARTY WEBSITE / MOBILE APPLICATIONS

  1. This website / mobile application may contain links or references to other website / mobile applications, including those of advertisers (“third party website / mobile applications“) which are not under Runako Connect’s control.

  2. The provisions of this Privacy Policy are not applicable to third party website / mobile applications and Runako Connect shall not be responsible for the information processing practices and/or privacy policies of those third party website / mobile applications, or the cookies that those website / mobile applications may use.

 

DIRECT MARKETING

  1. The User hereby consents to the processing of their personal information for the purpose of direct marketing by means of electronic communications including SMS’s or electronic mail.

  2. Where a User is a pre-existing customer, Runako Connect shall be entitled, without the User’s consent, to sending electronic communications to the User for the purpose of marketing similar products or services offered by Runako Connect.

  3. The User may object, free of charge, and without unnecessary formality, to the use of their details either when the information was first collected from them or when each subsequent electronic communication is sent to them by Runako Connect.

  4. The User can opt out of receiving further marketing communications by un-checking certain boxes on the forms used on the website / mobile application to collect their personal information, or by contacting Runako Connect at support@runakoconnect.co.zw

 

CHILDREN’S PERSONAL INFORMATION

  1. Runako Connect shall not process any personal information relating to a person under the age of 16 years unless it has obtained consent from that person’s parent or legal guardian. If this website / mobile application is being accessed by the parent or guardian of a child under the age of 16 years, and personal information pertaining to that child is being provided by the parent or guardian, then they hereby expressly consent to Runako Connect processing such information according to the further provisions of this Privacy Notice.

 

 

CROSS BORDER TRANSFERS OF PERSONAL INFORMATION

  1. Subject to clause 19.2, Runako Connect does not intend sharing a User’s personal information with a third party in another country.

  2. Runako Connect may transfer personal information to another country in the following circumstances:

    1. the transfer is necessary for the conclusion or performance of a contract with a third party which is for the benefit of or in the interest of the User;

    2. the transfer is otherwise for the benefit of the User; or

    3. the User has consented to the transfer of their information.

  3. If Runako Connect is required to transfer personal information from Zimbabwe to a third party in a foreign country, it shall ensure that the third party is subject to a law, binding code of conduct or contract which effectively upholds principles for the reasonable processing of personal information which are substantially similar to the data protection offered in Zimbabwe.

 

RETENTION OF INFORMATION

  1. Runako Connect will keep a record of any personal information collected for no longer than is necessary to achieve the specific purpose for which it collected such information in the first place unless:

    1. It is required by law to keep a record of such information for a longer period of time; or

    2. It needs to keep a record of such information for another lawful purpose; or

    3. It has a contractual obligation to keep a record of such information; or

    4. The User has consented to their information being kept for a longer period.

  2. Runako Connect may, if it has de-identified personal information, kept such information for historical, statistical or research purposes. Runako Connect shall ensure that appropriate safeguards are in place to prevent those records from being used for any other purposes, or against the information being re-identified.

 

RETURNING, DESTROYING OR DELETING PERSONAL INFORMATION

  1. Where Runako Connect is no longer authorised to retain a record of any personal information, it shall either:

  2. ensure that the information is permanently destroyed or deleted as soon as reasonably practicable; or

  3. return the information to the User or transfer it to a third party, if requested by the User in writing to do so.

 

 

CONSENT

  1. The User hereby consents to the processing of their personal information in terms of the provisions of this Privacy Policy.

  2. The User acknowledges and agrees that such consent has been given voluntarily after the User has read and understood the provisions of this Privacy Policy, in particular, regarding the following:

    1. the types of personal information to be processed;

    2. the specific processing activities to be undertaken;

    3. the specific purpose/s for such processing; and

    4. the possible consequences for the User that may arise from such processing.

  3. Should a User wish to withdraw any consent previously given by the User, they must notify Runako Connect’s information officer in writing or by email to support@runakoconnect.co.zw

 

 

LODGING AN OBJECTION

  1. A User may, on reasonable grounds, object to the processing of their personal information at any time after that processing has started.

  2. If a User wishes to object to the processing of their personal information, they must send written notice of their objection to Runako Connect’s information officer, together with their reasons for doing so.

  3. Choice of Law

    1. This Privacy Notice shall be governed and interpreted in accordance with the laws of Zimbabwe

 

 

AMENDMENT OF THIS PRIVACY NOTICE

  1. Runako Connect reserves the right to change, update, add, remove and/or amend any of the provisions of this Privacy Notice from time to time. Such changes, updates, additions, removals or amendments will become effective from the date of their publication on this website / mobile application.

  2. It is the User’s obligation to periodically check the provisions of this Privacy Notice for any such changes, updates, additions, removals or amendments.

  3. The User’s continued use of this website / mobile application following any changes, updates, additions, removals or amendments to this Privacy Notice will be considered notice of the User’s acceptance to abide by and be bound by this Privacy Notice, as amended.